Edelman v. Source Healthcare Analytics, LLC

265 F. Supp. 3d 534
CourtDistrict Court, E.D. Pennsylvania
DecidedJuly 18, 2017
DocketCIVIL ACTION NO. 16-6280
StatusPublished
Cited by3 cases

This text of 265 F. Supp. 3d 534 (Edelman v. Source Healthcare Analytics, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edelman v. Source Healthcare Analytics, LLC, 265 F. Supp. 3d 534 (E.D. Pa. 2017).

Opinion

MEMORANDUM

EDUARDO C. ROBRENO, J.

Plaintiff Laurel Edelman (“Plaintiff’) brings this action against Defendants Source Healthcare Analytics, LLC (“SHA”), her former employer, and Connie Shaffer, SHA’s Senior Director of Human Resources (together, “Defendants”), alleging that they (1) wrongfully terminated Plaintiffs employment following her knee surgery in violation of the Family Medical Leave Act (“FMLA”), 29 U.S.C. § 2601 (Counts I and II); and (2) failed to pay Plaintiff all wages due under Pennsylvania’s Wage Payment and Collection Law (“WPCL”), 43 Pa. Cons. Stat. § 260.1 (Count III).

After the Court granted Defendants’ first motion to dismiss Counts I and III as to both Defendants and Count II as to Shaffer, Plaintiff filed an Amended Complaint. Defendants now move to dismiss Counts I and II as to Shaffer, and Count III as to both Defendants, on the basis that Plaintiff fails to state a claim. Plaintiff opposes the motion.

For the reasons that follow, the Court will deny Defendants’ motion to dismiss Plaintiffs Amended Complaint.

I. FACTUAL BACKGROUND

Plaintiff alleges the following facts, all of which are presumed to be true for the purposes of resolving this motion.

Plaintiff was employed by SHA as a National Account Director from December 2014 through February 11, 2016. Am. Compl. ¶ 7, ECF No. 19. During her employment, Plaintiff was responsible for various accounts, including federal government contracts. Id. ¶ 9. In July and August 2015, Plaintiff advised senior executives of SHA that she believed SHA was not in compliance with various obligations under those federal government contracts and federal law, including the Health Insurance Portability and Accountability Act (“HIPAA”). Id. ¶¶ 10-11.

In October 2015, Plaintiff learned that she would need double knee replacement surgery. Id. ¶¶ 12-13. In mid-October, Plaintiff contacted Shaffer, SHA’s Senior Director of Human Resources, and informed her that Plaintiffs surgery was scheduled for November 9, 2015. Id. ¶ 13. Shaffer confirmed that Plaintiffs leave time would include short-term disability leave and FMLA leave. Id. Defendants also requested that Plaintiff complete and return short-term disability and FMLA medical forms. Id. ¶ 14. Plaintiff and her physician completed and returned those forms to Defendants. Id. SHA approved and permitted the issuance of Plaintiffs short-term disability benefits as part of her FMLA leave.1 Id

On November 9, 2015, Plaintiff had her scheduled knee replacement surgery. Id. ¶ 15. On January 5, 2016, Plaintiff emailed her immediate supervisor, Shaffer, and SHA’s human resources executive and informed them that she could return to work as of that date, so long as SHA could provide a reasonable accommodation to limit her long distance or plane travel until [537]*537February 15, 2016. Id. ¶ 18. Plaintiff provided a note from her physician supporting her request for an .accommodation, which is attached to the Amended Complaint. Id Around the same time, SHA began contacting Plaintiff with various work-related requests, which Plaintiff fulfilled. Id ’

Plaintiff received no substantive reply from SHA regarding her request to return to work. Id. ¶ 19. She contacted SHA again on January 21, 2016, and again on January 29, 2016, to inquire about returning to work. Id. In Plaintiffs January 29 request, she stated that she could return to work on February 1, 2016, with only minimal restrictions on her ability to travel for two weeks. Id She again received no response. Id. Instead, Defendants advised and directed Plaintiff to take additional time off work, and return to work on February 11, 2016. Id. ¶ 21.

Following Defendants’ representations and instructions, Plaintiff returned to work on February 11, 2016. Id. ¶ 22. Upon her return, Defendants immediately notified Plaintiff that her employment was terminated, effective that same day. Id. Defendants orally informed Plaintiff that, although the FMLA requires an employer to restore an employee to the same or an equivalent position following the employee’s return to work from FMLA leave, Defendants could terminate Plaintiff without violating the FMLA, because Plaintiff had exceeded , the twelve weeks of leave permitted under the FMLA. Id. ¶ 23. Defendants also informed Plaintiff that her position was “eliminated” because SHA was ending its involvement in the government contracting business. Id.

According to Plaintiff, Defendants’ rationale for her termination — that SHA was exiting the government contracting business — was merely a pretext. Id. ¶23. Plaintiff alleges that at the same time that SHA terminated Plaintiffs employment, SHA was actively recruiting prospective, candidates to fill her position. Id. ¶ 24. In support of this allegation, Plaintiff has .attached copies of SHA’s online job posting for a National Account Director. See Am. Compl. Ex. G. With regards to Shaffer specifically, Plaintiff alleges that Shaffer is personally liable because she exerted control over Plaintiffs leave and over SHA’s family medical leave policies. Id. ¶52. Plaintiff has attached email correspondence between her and Shaffer, illustrating that Shaffer also directed Plaintiff on the type of leave to take. See id. Ex. C.

Plaintiff also alleges that, at the time of her termination, SHA owed her various work-related business expense reimbursements, bonuses, and commissions. Id. W 26-27. Specifically, Plaintiff alleges that, at the time of her departure from SHA, she was entitled to (1) reimbursement for business expenses; and (2) commission payments for new or renewal contracts Plaintiff secured for SHA. See id. ¶¶ 72-86. Plaintiff alleges that Defendants refused to pay Plaintiff these amounts unless and until Plaintiff executed a “Separation and Release Agreement,” in' which Plaintiff would waive all of her employment-related legal claims. Id. ¶ 27.

II. PROCEDURAL HISTORY

Plaintiff initiated this action on December 2, 2016. ECF No. 1. Plaintiffs initial complaint asserted claims against both Defendants for (1) interference in violation of the FMLA (Count I); (2) retaliation in violation of the FMLA (Count II); and (3) breach of contract and violations of the WPCL (Count III).-See id. ¶¶ 30-90.

On February 8, 2017, Defendants moved to dismiss Counts I and III against both Defendants, and Count II against Shaffer. ECF No. 11. Plaintiff filed an opposition brief on February 21, 2017. ECF No. 14. On March 6, 2017, following a hearing, the [538]*538Court' granted the motion, and dismissed Counts I and III against both Defendants,- and Count II against Shaffer, without prejudice. ECF No. 17. The Court also granted Plaintiff leave to file an Amended Complaint. See id.

Plaintiff filed an Amended Complaint on March 17, 2017. ECF No. 19. The Amended Complaint brings claims against both Defendants for (1) interference in violation of the FMLA (Count I); (2) retaliation in violation of the FMLA (Count II); and (3) breach of contract and violations of the WPCL (Count III). See id. ¶¶ 30-90. Plaintiff seeks all unpaid wages and expense reimbursements owed, in addition to liquidated damages, interest, costs, and attorneys’ fees. Id. at 22.

Defendants moved to dismiss the Amended Complaint on March 31, 2017, ECF No.

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265 F. Supp. 3d 534, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edelman-v-source-healthcare-analytics-llc-paed-2017.